Case Summary (G.R. No. 175025)
Factual Antecedents
In 1966, Barangan entered into a Land Purchase Agreement with Citadel Realty Corporation to acquire a 300-square meter lot, ultimately obtaining TCT No. N-10772 after full payment in 1976. Barangan consistently paid real property taxes but could not occupy the land due to his military assignments. Upon attempting to visit his property in 1993, he discovered it occupied by Dulfo's family. Following unsuccessful demands for them to vacate, Barangan filed a complaint under the Anti-Squatting Law, which was dismissed for lack of ownership determination. A subsequent survey confirmed Dulfo’s occupation overlapped with Barangan’s titled property, leading to Dulfo and Jakosalem’s defense asserting that they possessed the property since 1979, claiming ownership based on prior assignments.
Ruling of the Regional Trial Court
On March 19, 2003, the Regional Trial Court (RTC) ruled in favor of Dulfo and Jakosalem, citing Barangan’s insufficient evidence to affirm ownership and asserting the defenses of prescription and laches. The RTC ordered Barangan to pay damages counterclaimed by the petitioners.
Ruling of the Court of Appeals
The Court of Appeals (CA) overturned the RTC’s decision, determining Barangan sufficiently demonstrated ownership through his title and identified the property through witness testimonies and survey evidence. The CA ruled for possession recovery and ordered petitioners to pay for the property’s use and damages.
Issues
Key issues addressed included the identification of the property under TCT No. N-10772, the ability of Barangan to satisfy legal requirements for possession recovery, the reasonableness of the rental amount, and the applicability of laches and prescription in this context.
Petitioners' Arguments
Dulfo and Jakosalem contended that the survey identifying the property was invalid, claiming prior agreements for joint surveys were violated. They argued the discrepancy between title numbers indicated misidentification of the property and formulated defenses based on the doctrines of laches and prescription. Furthermore, they claimed the awarded damages were excessive.
Respondent's Arguments
Barangan maintained that his registered title entitled him to possession, asserting that no delay existed that would invoke laches or prescription against claims involving registered land.
Our Ruling
The Supreme Court affirmed the CA’s decision, concluding Barangan met the burden of proving ownership and property identity. Barangan's title under the Torrens system was held superior, and his right to recover this property was reaffirmed, independent of petitioners' claims. Petitioner arguments regarding survey participation were dismissed due to their previous refusal to engage constructively. The Court clarified that no discrepancies between title numbers obstructed Barangan’s claims, and prior defenses citing laches and prescription were rejected since such defense
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Background and Factual Antecedents
- Respondent Roberto S. Barangan entered into a Land Purchase Agreement on August 13, 1966, for a 300-square meter property in Antipolo, Rizal, covered by TCT No. 165456.
- Upon full payment, a Deed of Absolute Sale was executed on August 31, 1976, and title transferred to TCT No. N-10772 in Barangan's name.
- Barangan consistently paid real property taxes but had not physically occupied the property due to military assignments.
- In December 1993, upon preparing for retirement and intending to build a house, Barangan discovered the property was occupied by petitioner Dulfo and his family.
- Barangan demanded the occupants vacate through a letter dated February 4, 1994; a counterclaim of ownership was asserted by petitioner Jakosalem, Dulfo's son-in-law.
Procedural History
- Barangan filed an anti-squatting complaint on February 19, 1994, which was dismissed due to ownership issues requiring civil action.
- On May 28, 1994, Barangan commissioned a relocation survey confirming that the property occupied by petitioners is the same as that covered by his title.
- Barangan filed a Complaint for Recovery of Possession on November 17, 1994, including claims for unpaid rent, damages, and costs.
- Petitioners answered claiming an assignment from Nicanor Samson, their possession since 1979, and disputed the identity of the property.
Trial Proceedings and Evidence
- Barangan testified and presented witnesses: a caretaker confirming petitioners' squatting, a municipal assessor's representative attesting to property registration, and the surveyor verifying property identity.
- Petitioners moved to dismiss on demurrer to evidence but were denied; they presented Jakosalem who claimed property assignment and requested ocular inspection.
- The court ordered a DENR resurvey, which did not proceed as petitioners abandoned the request.
Regional Trial Court Ruling
- On March 19, 2003, the RTC ruled against Ba